Google FCC Wireless Application

PUBLIC REDACTED VERSION
Google Inc.
File No. 0539-EX-PL-2016
Date:
August 5, 2016
Subject:
Public and Redacted Versions of Request for Condential Treatment and

Complementary Exhibits
File Number:
0539-EX-PL-2016
To Whom It May Concern:

Google Inc. (Google), pursuant to 5 U.S.C. 552 and Sections 0.457 and 0.459 of the
Commission's Rules, 47 C.F.R. 0.457, 0.459, hereby requests that certain information
complementary to its above-referenced application for an Experimental Radio Service License
(Experimental License) be treated as condential and not subject to public inspection. The
designated information constitutes condential and proprietary information that, if subject to
public disclosure, would cause signicant commercial, economic, and competitive harm. As
described below, Googles request satises the standards for grant of such requests set forth in
Sections 0.457 and 0.459 of the Commissions Rules.
In accordance with Section 0.459(b) and in support of this request, Google provides the
following information:
1.
Identication of the Information for Which Condential Treatment is Sought:
Googles request for condential treatment is limited to information that has been
redacted from the Experimental License and Exhibits A and C. Google does not seek to
withhold from public inspection information in the Experimental License and associated exhibits
necessary for interference mitigation, including applicant name, contact information, test
location, frequency, output power, effective radiated power, emission characteristics, and
modulation.
Exhibit A - Narrative Statement:
Google requests condential treatment of the following underlined text from Exhibit A
that contain condential and proprietary information regarding the proposed
tests/experiments:
Consistent with the standards set forth in Section 5.63 of the Federal
Communications Commissions (Commissions) Rules, 47 C.F.R. 5.63, Google
Inc. (Google) requests authorization to conduct radio experiments in support of
developing Citizens Broadband Radio Service (CBRS) technologies, using
[REDACTED] experimental transmitters at up to 24 U.S. locations. The
experimental authorization is sought for a period of 24 months. Google outlines
Request for Condential Treatment - Page 1

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below its need for the requested authorization and the reasons why it should be
granted expeditiously.
Background
In establishing the CBRS, the Commission opened a door for wireless
innovation and bandwidth abundance. Rather than allocating the 3.5 GHz band to
a single use, the Commission rightly decided to allow shared use of the
spectrum. Users of the spectrum might, for instance, deploy small cell networks
that can carry heavy loads of data in high-trafc areassuch as crowded
stadiumsor offer xed wireless broadband services in rural areas. The
additional spectrum that is now available in the 3.5 GHz band will also help
relieve Wi-Fi congestionimproving the experience of consumers accessing the
Internet over wireless broadband.
A key component to sharing in this band is the Spectrum Access System

(SAS), which utilizes database technology to protect important federal
government uses of spectrum. These systems will ensure that neither priority
access nor general authorized access users interfere with the existing
government and private users who will continue to need 3.5 GHz spectrum in a
limited number of areas. SAS database systems also will allow new users to
share effectively with each other. Google has been a leader in using databases to
free-up available spectrum, and it is one of the companies working to develop a
sharing system for the 3.5 GHz band.
The instant experimental authorization is needed to advance technologies
in the 3.5 GHz band. Specically, the experimental authorization will allow Google
to continue its experimentation with propagation and [REDACTED]. As discussed
further below, the parameters of the experimental authorization will protect
incumbent operators from harmful interference. Indeed, there have been no
reports of interference from Googles ongoing experimental operations under call
signs WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) and WI2XFG
(File No. 0095-EX-PL-2016).1
Google requests authorization to operate in and adjacent to the
3550-3700 MHz band that has been opened for innovative small-cell spectrum
sharing by CBRS devices. Google requests authorization to operate on
frequencies down to 3400 MHz and up to 3800 MHz so that [REDACTED].
Authority to operate in this range will ensure that Google has access to sufcient
spectrum for experimentation while avoiding interference to incumbent
operations, including federal government operations and operations under Parts
Call sign WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) is associated with 3550-3700
MHz operations in Mountain View, CA, Arlington, VA, and Reston, VA. That experimental authorization is
set to expire in December 2016. If this request for experimental authorization is granted, Google plans to
let its authorization under WH2XNF expire and experimental operations at those three locations would
continue under the new authorization.

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25 and 90 of the Commissions rules.

The proposed experimentation will allow Google to perform propagation,
[REDACTED] testing [REDACTED]. Data obtained from these tests will be reected
in the design of Googles commercial SAS, which is currently under development
to serve users in the new CBRS band. Specically, together with testing under call
signs WH2XNF and WI2XFG, the proposed testing will assist in enabling: (1)
[REDACTED]; (2) [REDACTED]; and (3) [REDACTED]. [REDACTED]. [REDACTED].
Planned Operations
Google anticipates performing the following tests under the requested
experimental authorization. As described in the next section, the proposed
experimental operations in the 3.5 GHz band will be conducted without harmful
interference to other authorized users.
Propagation Testing: Google will use both a simple continuous wave

(CW) tone and a broadband signal to understand the effects of clutter
loss, differential fading, multipath, and other propagation phenomena. To
test [REDACTED], Google will use a mobile receiving station [REDACTED].
Google may also position [REDACTED]. In each local test area, Google will
generally operate only [REDACTED] while conducting propagation tests.
Testing of [REDACTED]: Google will test [REDACTED]. In Atlanta, Austin,

and Provo, Google will use [REDACTED].
[REDACTED] Testing: Google will [REDACTED]. [REDACTED] .
[REDACTED] Testing: Google will investigate [REDACTED].
In order to perform these tests, Google seeks authorization to operate

[REDACTED] experimental transmitters per test area. Specically, Google seeks
authorization for [REDACTED] eNodeBs (also referred to as access points or base
stations) and [REDACTED] end user devices (EUDs) that will communicate with
the eNodeBs ([REDACTED] EUDs per [REDACTED] eNodeB on average). Google
will deploy this equipment [REDACTED] within the proposed areas of operation. It
is unlikely that [REDACTED], or the full number of authorized devices, will ever
transmit simultaneously. Rather, the full complement of test areas is needed to
ensure sufcient diversity of test environments.
Google requests authorization to transmit in a variety of locations and
environments that meet several characteristics, including the radio propagation
environment, height and variety of clutter (buildings and foliage), existence of
suitable Google infrastructure and resources to support experimentation, and
existence of partners who may participate in the tests. To that end, Google
requests authorization to conduct testing in up to 24 U.S. areas. The test areas
will be selected from the list of locations in Exhibit B. All test areas will be subject
to the same limit of [REDACTED] experimental transmitters, and none of the
areas will have a radius of operations greater than 40 kilometers. See Exhibit B

Google Inc.
for the proposed radius of operation for each of the potential test locations.
From the list in Exhibit B, Google plans to deploy initially in Atwater,
California, Mountain View, California, Palo Alto, California, San Bruno, California,
San Francisco, California, San Jose, California, Boulder, Colorado, Kansas City,
Kansas,2 Omaha, Nebraska, Raleigh, North Carolina, Provo, Utah, and Reston,
Virginia.
EUDs operating under the requested authorization will be used by
Googles employees and contractors. Such devices may also be used, under
close supervision, by trusted testers selected by Google on a volunteer basis
without payment. No commercial operations will be conducted under the
requested authorization and all equipment will be collected at the end of the
experimentation period.
Interference Analysis
The 3400-3800 MHz frequency range covers multiple allocated bands and
a variety of incumbent systems and services. As described below, Google will
deploy and operate its equipment under this experimental authorization in a
manner that will avoid interference to other authorized users.
Transmit Power and Out-of-Band Emission Considerations
Most operations under this experimental authorization will be conducted
within the Part 96 Category B CBSD EIRP limit of 47 dBm per 10 MHz.
Experimentation will also be conducted within the Category A CBSD EIRP limit of
30 dBm per 10 MHz. [REDACTED], Google requests authorization to operate up to
a conducted power spectral density (PSD) limit of 40 dBm per 10 MHz and a
radiated PSD of 57 dBm per 10 MHz. [REDACTED], Google also requests
authorization to operate up to a total conducted power limit of 49 dBm [40 dBm +
10log(8)] and a maximum radiated power (EIRP) of 66 dBm. The requested
maximum conducted and radiated power limits will provide exibility to support a
wide range of complementary advanced technology development and
experimentation. [REDACTED].3 [REDACTED]. [REDACTED].
Additionally, Google requests authority to conduct narrowband
propagation testing in the 3550-3575 MHz segment using a maximum conducted
power of 47 dBm and a maximum radiated power of 77 dBm (assuming the use
of a high-gain, narrow beamwidth 30 dBi antenna). [REDACTED]. [REDACTED].
Google notes that extensive propagation testing has been conducted in this band
under its existing experimental authorization (call sign WH2XNF) in the densely
populated areas of Arlington, Virginia, and Mountain View, California, with no
reports of interference. Google has chosen the 3550-3575 MHz portion as it is
2
Call sign WI2XFG (File No. 0095-EX-PL-2016) is associated with 3400-3700 MHz operations in the
Kansas City area. In the present application, Google requests authority to operate up to 3800 MHz in a
limited section of Kansas City, KS.
3
See [REDACTED].

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removed by at least 75 MHz from the nearest adjacent-band allocation.

Furthermore, the possibility of interference to authorized users of the band will be
mitigated by using narrow beamwidth antennas and narrowband CW
transmissions, along with out-of-band emission levels that will meet or exceed
(i.e., be lower than) the limits in Section 96.41(e) of the Commissions Rules, 47
C.F.R. 96.41(e).
In summary, Google requests authorization to operate up to the following
power limits:
Planned Testing
Conducted Power Limits
Radiated Power Limits
Broadband Network
(3400-3800 MHz)
40 dBm per 10 MHz power

spectral density
49 dBm total conducted

power (assumes eight
10-MHz aggregate
channels)
57 dBm per 10 MHz

radiated power spectral
density
66 dBm total radiated

10-MHz aggregate
channels)
Narrowband Propagation 47 dBm

(3550-3575 MHz)
77 dBm
Below, Google explains its plans for protection of the following incumbent
users in the 3400-3800 MHz frequency range.
Frequencies
Users
3400-3500 MHz
Military radar systems

Amateur radio
3500-3650 MHz
Shipborne military radar systems
3600-3700 MHz
Grandfathered FSS receive-only earth

stations
3650-3700 MHz
Ground-based military radar systems

Part 90, Subpart Z operators
3700 MHz
FSS receive-only earth stations
Protection of Military Radar Systems Below 3500 MHz

In the 3100-3500 MHz band, the U.S. military operates radar systems on
ships and at several land-based military installations around the country. To

Google Inc.
protect such uses, Google will ensure that the signals from its experimental
operations remain at or below levels that would reasonably preclude the
possibility of interference. Specically, for all test locations within the coastal
exclusion zones (see Figures 1-3 below) or within 150 km of an in-land
operations area, Google will use the NTIA propagation model that was used to
compute the coastal exclusion zones4 (hereafter referred to as the NTIA model)
to predict the aggregate interference from its deployed transmitters operating at
or below 3550 MHz to the closest point of the military operations area (coastal or
land-based) and will limit its signal strength to at or below the ambient noise level
of -174 dBm/Hz at that point, as received by an isotropic antenna. In the
calculation, Google will include both fundamental emissions below 3500 MHz
and out-of-band emissions from devices operating above 3500 MHz.
Amateur Radio Operations in 3400-3500 MHz
The amateur radio service has a secondary allocation in the 3300-3500
MHz band (3.4 GHz band). Based on Googles spectrum monitoring elsewhere in
the U.S., amateur operation in this band appears to be infrequent and generally
point-to-point. However, Google will coordinate with the amateur radio
community to ensure that Googles operations do not interfere with any amateurs
who may be utilizing the 3.4 GHz band. For example, Google will inform the
American Radio Relay League prior to beginning operations in each area and
provide contact information so they can report any suspected interference.
Protection of Shipborne Military Radar Systems in 3500-3650 MHz
In the 3500-3650 MHz band, the U.S. military operates shipborne radars in
coastal areas. To protect such uses, Google will ensure that the signals from the
experimental operations remain at or below levels that would reasonably
preclude the possibility of interference. Alternatively, if operating such that the
signals could exceed the interference threshold at the coast, Google will operate
a sensor to detect military radar operations and recongure its devices to avoid
those frequencies during the operations.
Specically, for all test locations within the coastal exclusion zones
established by the Commission5 (see Figures 1-3 below), Google will use the
NTIA model to predict the aggregate interference from its deployed transmitters
to the closest point on the coast6 and limit the signal strength to at or below the
4
The model is described on the NTIA website at

https://www.ntia.doc.gov/report/2015/35-ghz-exclusion-zone-analyses-and-methodology.
5
See 47 C.F.R. 96.15(a)(1), 96.15(a)(3), 96.15(b); see also Letter from Paige Atkins, Associate
Administrator, Ofce of Spectrum Management, National Telecommunications and Information
Administration, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 12-354, at Enclosure 1 (proposing
exclusion zones to protect shipborne radars).
6
In the event of unusual local geography (e.g., a hill or mountain that blocks the path to the nearest point
on the coast but does not block other paths starting a short distance from that point), Google will analyze
paths to a range of points on the coast and ensure that its signal does not exceed the interference
threshold at any of those points.

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ambient noise level of -174 dBm/Hz at that point, as received by an isotropic

antenna. In the calculation, Google will include both fundamental emissions in
3500-3650 MHz and out-of-band emissions from devices operating below 3500
MHz and above 3650 MHz. If the signal level is predicted to exceed -174 dBm/Hz
at the closest point on the coast, Google will deploy a sensor to detect military
radar operations offshore and congure its devices to avoid the frequency at
which the military is operating, and +/-5 MHz on either side. This is consistent
with the operational concept of the ESC in the Part 96 rules.7 Google will use a
prototype ESC sensor for this purpose, which will be designed to meet the
WinnForum requirements on ESC sensitivity.8
Protection of Grandfathered FSS Receive-Only Earth Station Operations in
3600-3700 MHz
In the 3600-3700 MHz band, FSS receive-only earth stations operate on a
grandfathered basis in accordance with the FCCs rules.9 The earth stations are
located at 35 sites that are largely clustered along the coasts.10 For all test areas
subject to Grandfathered FSS Operations protection requirements (see Figures
1-3 below), Google will meet the Part 96 requirements11 and will conduct its
calculations using the NTIA model. In the event that Googles predictions show
that the Part 96 limits may be exceeded for a particular site, Google will
coordinate with the operators of the affected earth station(s).
Protection of Ground-based Military Radar Systems in 3650-3700 MHz
In the 3650-3700 MHz band, the U.S. military conducts research and
development (R&D) activity at three land-based sites whose coordinates are
listed in the FCCs rules.12 To protect such uses, Google will ensure that the
signals from its experimental operations remain at or below levels that would
reasonably preclude the possibility of interference. Specically, for all test
locations within 150 km of the R&D sites,13 Google will use the NTIA model to
predict the aggregate interference from its deployed transmitters to the R&D sites
and will limit its signal strength to at or below the ambient noise level of -174
dBm/Hz at that point, as received by an isotropic antenna. In the calculation,
Google will include both fundamental emissions in 3500-3650 MHz and
7
See 47 C.F.R. 96.67.

Specically, [a]n ESC shall be capable of detecting an in-band incumbent radar over a maximum
propagation loss from the radar of 184 dB on the coastline and given a sufciently elevated sensor
location (e.g. 25m) with a clear line-of-sight to the horizon. WINNF-15-S-0112-V1.0.0 CBRS Operational
and Functional Requirements at 27, available online at
http://groups.winnforum.org/p/cm/ld/d=85&tid=338&sid=5781.
9
See 47 C.F.R. 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US107.
10
The sites are listed on the Commissions website at
https://www.fcc.gov/general/35-ghz-band-protected-xed-satellite-servicefss-earth-stations.
11
See 47 C.F.R. 96.17.
12
S
ee 47 C.F.R. 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US109.
13
Consistent with the proposed power levels for its experimental operations, Google will observe a 150
km exclusion zone instead of the 80 km exclusion required by 47 C.F.R. 9
6.15(b)(2).
8

Google Inc.
out-of-band emissions from devices operating below 3500 MHz and above 3650
MHz. In general, Google will avoid operating in the 3650-3700 MHz band unless
necessary for the purpose of the experiment, as there are many incumbents in
this band segment in addition to the military radar operations.
Protection of Part 90 Incumbents in the 3650-3700 MHz Band
To protect existing Part 90 operations in the 3650-3700 MHz band,
Google will coordinate its proposed experimental transmissions in this band with
all Part 90 licensees in the Commissions ULS database that are within 25 km of
a Google transmitter location. Because there are many Part 90 systems
operating in this band segment, and because Google plans to coordinate with
adjacent-band FSS sites, Google will generally avoid using the 3650-3700 MHz
band except when necessary to meet testing objectives, [REDACTED].
Protection of FSS Receive-Only Earth Station Operations in the 3700-4200
MHz Band
Numerous FSS receive-only earth stations operate in the 3700-4200 MHz
band (C-band). To protect such uses, Google will meet the protection
requirements for these systems as established in Part 96. Once again, Google
will conduct its calculations using the NTIA model. Google will meet the in-band
protection requirements in 47 C.F.R. 96.17(a), extended to 3700-4200 MHz,
since Google will be operating in-band in this segment. In the event that Googles
predictions show Part 96 limits may be exceeded for a particular site, Google will
coordinate with the operators of the affected earth station(s). As previously
noted, Google intends to avoid operations above 3600 MHz due to the number of
incumbents, unless such operations are necessary to meet the objectives of the
experiments.
Figures
The following gures show the locations of Googles planned and
potential test areas relative to the locations of incumbents requiring interference
protection. The following key applies to the gures:
Green areas: Locations where Google plans to operate under the

requested experimental authorization, if approved.
Blue areas: Locations where Google may operate under the requested
experimental authorization, if approved.
Gold-colored areas: Protection zones for incumbent federal ground-based
radar operations in the 3100-3500 MHz band.
Red lines: Coastal exclusion zones for incumbent U.S. military shipborne
operations in the 3500-3650 MHz band.
Red circles: Exclusion zones for incumbent U.S. military R&D sites in the
3650-3700 MHz band, calculated using a 150 km exclusion distance.

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Red dots: Incumbent FSS earth stations in the 3600-3700 MHz band.
Figure 1: Nationwide view of planned and potential test areas

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Figure 2: Close-up of San Francisco Bay area

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Figure 3: Close-up of Reston, VA area

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Conclusion
The proposed experimental operations will advance radio technologies
associated with the new CBRS service and be conducted without harmful
interference to other authorized users. For the foregoing reasons, Google
requests approval of this application.
Exhibit C - Technical Information:
Google requests condential treatment of the following underlined text from Exhibit C
that contain condential and proprietary information regarding the proposed
tests/experiments:
Applicant Name:
Google Inc.
Applicant FRN:
0016069502
Legal Contact Details

Name of Contact
Stephanie Selmer
Contact Details
Associate Corporate Counsel

25 Massachusetts Avenue NW, Ninth Floor
Washington, DC 20001
Technical Contact Details

Name of Contact
Dr. Andrew Clegg
Contact Details
1875 Explorer Street, Tenth Floor

Reston, VA 20190
Phone: (202) 370-5644
Email: aclegg@google.com

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Transmitter Equipment and Station Details

Radio Information
Equipment
[REDACTED]
Quantity
[REDACTED]
Area of Operation
Operations vary from 7 km to 40 km from the

geographic centerpoint of each test area. See
Exhibit B for the specic areas of operation.
Frequency
High (MHz)
Low (MHz)
3800
3400
[REDACTED]
Amplier Information
Equipment
[REDACTED]
Quantity
[REDACTED]
Area of Operation

Antenna Details
Antennas
[REDACTED]
Type
Both directional and omnidirectional antennas

will be used.
Quantity
[REDACTED]
Gain
30 dBi max; -4 dBi min
Beam Width at
Half-Power Point
Various (5 to 360 Horizontal; 5 to 180 Vertical)
Orientation in
Horizontal Plane
Various (0 to 360)
Orientation in
Vertical Plane
10 to -30

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Radio
Modulation
Emission Bandwidth Maximum Maximum

Designator
Power
EIRP/ERP
Out
[REDACTED]
Continuous 10H0N0N
waveform
10 Hz
50 W14
EIRP =
47 dBW
(50 kW)14
ERP =
44.9 dBW
(31 kW)14
(with 30
dBi
antenna)
[REDACTED]
Digital
10M0W7D
20M0W7D
40M0W7D
60M0W7D
80M0W7D
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
[REDACTED]
Digital
10M0F9W
20M0F9W
40M0F9W
60M0F9W
80M0F9W
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
[REDACTED]
Digital
10M0G7D
20M0G7D
40M0G7D
60M0G7D
80M0G7D
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
[REDACTED]
Digital
10M0GXW
20M0GXW
40M0GXW
60M0GXW
80M0GXW
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
For 10 W
conducted:
EIRP =
27 dBW
(500 W);
ERP =
24.9 dBW
(305 W)
For 20 W
conducted:
EIRP =
30 dBW
(1000 W);
ERP =
27.9 dBW
(611 W)
For 40 W
conducted:
EIRP =
33 dBW
(2000 W);
ERP =
30.9 dBW
(1222 W)
For 60 W
conducted:
EIRP =
34.8 dBW
(3000 W);
ERP =
32.6 dBW
14
Highpoweroperationlimitedto[REDACTED]inthe35503575MHzbandsegment.

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(1833 W)
For 80 W
conducted:
EIRP =
36 dBW
(4000 W);
ERP =
33.9 dBW
(2444 W)
(all with 17
dBi
antenna)
[REDACTED]
Digital
2M00P0N
2 MHz
4 W
[REDACTED]
Digital
5M00Q7N
10M0Q7N
20M0Q7N
5 MHz
10 MHz
20 MHz
4 W
EIRP =
22 dBW
(160 W)
ERP =
19.9 dBW
(98 W)
(with 16
dBi
antenna)
2.
Identication of the Commission proceeding in which the information was submitted or

a description of the circumstances giving rise to the submission.
Exhibits A and C were submitted to the Commission in support of the Experimental

License. The exhibits were led with the Ofce of Engineering and Technology on August 5,
2016. For additional information, please see File No. 0539-EX-PL-2016.
3.
Explanation of the degree to which the information is commercial or nancial or
contains a trade secret or is privileged.
The information requested to be kept condential has signicant commercial value. The
exhibits supporting the Experimental License discuss tests/experiments that include trade
secret information. The Commission has claried that condential treatment should be
15
afforded to trade secrets. Googles tests/experiments and proprietary wireless applications
using particular radio frequency equipment represent a secret commercially valuable plan
within the meaning of a trade secret as recognized by the Commission.
15
Examination of Current Policy Concerning the Treatment of Condential Information Submitted to the
Commission, Report and Order, GC Docket No. 96-55, at para. 3, (released Aug. 4, 1998) (dening trade
secrets for purpose of Commission rules on condential treatment).

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4.
Explanation of the degree to which the information concerns a service that is

competitive.
The services and technologies that are the subject of this Experimental License have not
yet been fully developed but are expected to lead to material developments in markets subject
to competition from multiple U.S. and non-U.S. third parties.
5.
Explanation of how disclosure of the information could result in substantial competitive
harm.
The technology under development is highly sensitive and condential in nature. The
release of such information would provide valuable insight into Googles technology innovations
and potential business plans and strategies. Public disclosure would jeopardize the value of the
technology under examination by enabling others to utilize Googles information to develop
similar products in a similar time frame.
6.
Identication of any measures taken by the requesting party to prevent unauthorized
disclosure.
Google has taken steps to keep condential the information set forth in the condential
exhibits by limiting the number of people involved in the tests/experiments to only those on a
need to know basis, and by requiring any third parties involved in the testing process to
execute robust nondisclosure agreements.
7.
Identication of whether the information is available to the public and the extent of any
previous disclosures of the information to any third parties.
The information contained in the condential exhibits is not available to the public, and
will only be disclosed to third parties pursuant to the restrictive safeguards described above.
Google voluntarily provides the information to the Commission at this time with the
expectation that it will be treated condentially in accordance with the Commission's rules. See
Critical Mass Energy Project v. Nuclear Regulatory Commn, 975 F.2d 871, 879 (D.C. Cir. 1992)
(commercial information provided on a voluntary basis is condential for the purpose of
Freedom of Information Act (FOIA) Exemption 4 if it is of a kind that would customarily not be
released to the public by the person from whom it was obtained.)
8.
Justication of the requested period of condentiality.
Google expects that condential treatment will be necessary for the length of the
proposed experiment and thereafter in order to protect its evolving business and technology
strategies.

Google Inc.
9.
Any other information that would be useful in assessing whether this request should be
submitted.
The information subject to this request for condentiality should not be made available
for public disclosure at any time. There is nothing material that public review of this information
would add to the Commissions analysis of Googles request for an experimental authorization.
Moreover, public disclosure of the sensitive information in the condential exhibits to the
Experimental License after the Commission has ruled on the Request for Condentiality is not
necessary for the Commission to fulll its regulatory responsibilities.
Consistent with 47 C.F.R. 0.459(d)(l), Google requests notication if release of the

information subject to this request is requested pursuant to the FOIA or otherwise, so that
Google may have an opportunity to oppose grant of any such request.
Sincerely yours,
Stephanie Selmer

Google Inc.
EXHIBIT A - NARRATIVE STATEMENT
Consistent with the standards set forth in Section 5.63 of the Federal Communications
Commissions (Commissions) Rules, 47 C.F.R. 5.63, Google Inc. (Google) requests
authorization to conduct radio experiments in support of developing Citizens Broadband Radio
Service (CBRS) technologies, using [REDACTED] experimental transmitters at up to 24 U.S.
locations. The experimental authorization is sought for a period of 24 months. Google outlines
below its need for the requested authorization and the reasons why it should be granted
expeditiously.
Background
In establishing the CBRS, the Commission opened a door for wireless innovation and
bandwidth abundance. Rather than allocating the 3.5 GHz band to a single use, the Commission
rightly decided to allow shared use of the spectrum. Users of the spectrum might, for instance,
deploy small cell networks that can carry heavy loads of data in high-trafc areassuch as
crowded stadiumsor offer xed wireless broadband services in rural areas. The additional
spectrum that is now available in the 3.5 GHz band will also help relieve Wi-Fi
congestionimproving the experience of consumers accessing the Internet over wireless
broadband.
A key component to sharing in this band is the Spectrum Access System (SAS), which
utilizes database technology to protect important federal government uses of spectrum. These
systems will ensure that neither priority access nor general authorized access users interfere
with the existing government and private users who will continue to need 3.5 GHz spectrum in a
limited number of areas. SAS database systems also will allow new users to share effectively
with each other. Google has been a leader in using databases to free-up available spectrum, and
it is one of the companies working to develop a sharing system for the 3.5 GHz band.
The instant experimental authorization is needed to advance technologies in the 3.5 GHz
band. Specically, the experimental authorization will allow Google to continue its
experimentation with propagation and [REDACTED]. As discussed further below, the parameters
of the experimental authorization will protect incumbent operators from harmful interference.
Indeed, there have been no reports of interference from Googles ongoing experimental
operations under call signs WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) and
WI2XFG (File No. 0095-EX-PL-2016).1
Google requests authorization to operate in and adjacent to the 3550-3700 MHz band
that has been opened for innovative small-cell spectrum sharing by CBRS devices. Google
requests authorization to operate on frequencies down to 3400 MHz and up to 3800 MHz so
that [REDACTED]. Authority to operate in this range will ensure that Google has access to
sufcient spectrum for experimentation while avoiding interference to incumbent operations,
1
Call sign WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) is associated with 3550-3700
MHz operations in Mountain View, CA, Arlington, VA, and Reston, VA. That experimental authorization is
set to expire in December 2016. If this request for experimental authorization is granted, Google plans to
let its authorization under WH2XNF expire and experimental operations at those three locations would
continue under the new authorization.
Exhibit A - Page 1

Google Inc.
including federal government operations and operations under Parts 25 and 90 of the
Commissions rules.
The proposed experimentation will allow Google to perform propagation, [REDACTED]
testing [REDACTED]. Data obtained from these tests will be reected in the design of Googles
commercial SAS, which is currently under development to serve users in the new CBRS band.
Specically, together with testing under call signs WH2XNF and WI2XFG, the proposed testing
will assist in enabling: (1) [REDACTED]; (2) [REDACTED]; and (3) [REDACTED]. [REDACTED].
[REDACTED].
Planned Operations
Google anticipates performing the following tests under the requested experimental
authorization. As described in the next section, the proposed experimental operations in the 3.5
GHz band will be conducted without harmful interference to other authorized users.
Propagation Testing: Google will use both a simple continuous wave (CW) tone and a
broadband signal to understand the effects of clutter loss, differential fading, multipath,
and other propagation phenomena. To test [REDACTED], Google will use a mobile
receiving station [REDACTED]. Google may also position [REDACTED]. In each local test
area, Google will generally operate only [REDACTED] while conducting propagation tests.
Testing of [REDACTED]: Google will test [REDACTED]. In Atlanta, Austin, and Provo,
Google will use [REDACTED].
[REDACTED] Testing: Google will [REDACTED]. [REDACTED].
[REDACTED] Testing: Google will investigate [REDACTED].
In order to perform these tests, Google seeks authorization to operate [REDACTED]

experimental transmitters per test area. Specically, Google seeks authorization for [REDACTED]
eNodeBs (also referred to as access points or base stations) and [REDACTED] end user devices
(EUDs) that will communicate with the eNodeBs ([REDACTED] EUDs per [REDACTED] eNodeB on
average). Google will deploy this equipment [REDACTED] within the proposed areas of
operation. It is unlikely that [REDACTED], or the full number of authorized devices, will ever
transmit simultaneously. Rather, the full complement of test areas is needed to ensure sufcient
diversity of test environments.
Google requests authorization to transmit in a variety of locations and environments that
meet several characteristics, including the radio propagation environment, height and variety of
clutter (buildings and foliage), existence of suitable Google infrastructure and resources to
support experimentation, and existence of partners who may participate in the tests. To that
end, Google requests authorization to conduct testing in up to 24 U.S. areas. The test areas will
be selected from the list of locations in Exhibit B. All test areas will be subject to the same limit
of [REDACTED] experimental transmitters, and none of the areas will have a radius of operations
greater than 40 kilometers. See Exhibit B for the proposed radius of operation for each of the
potential test locations.
From the list in Exhibit B, Google plans to deploy initially in Atwater, California, Mountain
Exhibit A - Page 2

Google Inc.
View, California, Palo Alto, California, San Bruno, California, San Francisco, California, San Jose,
California, Boulder, Colorado, Kansas City, Kansas,2 Omaha, Nebraska, Raleigh, North Carolina,
Provo, Utah, and Reston, Virginia.
EUDs operating under the requested authorization will be used by Googles employees
and contractors. Such devices may also be used, under close supervision, by trusted testers
selected by Google on a volunteer basis without payment. No commercial operations will be
conducted under the requested authorization and all equipment will be collected at the end of
the experimentation period.
Interference Analysis
The 3400-3800 MHz frequency range covers multiple allocated bands and a variety of
incumbent systems and services. As described below, Google will deploy and operate its
equipment under this experimental authorization in a manner that will avoid interference to
other authorized users.
Transmit Power and Out-of-Band Emission Considerations
Most operations under this experimental authorization will be conducted within the Part
96 Category B CBSD EIRP limit of 47 dBm per 10 MHz. Experimentation will also be conducted
within the Category A CBSD EIRP limit of 30 dBm per 10 MHz. [REDACTED], Google requests
authorization to operate up to a conducted power spectral density (PSD) limit of 40 dBm per 10
MHz and a radiated PSD of 57 dBm per 10 MHz. [REDACTED], Google also requests
authorization to operate up to a total conducted power limit of 49 dBm [40 dBm + 10log(8)] and
a maximum radiated power (EIRP) of 66 dBm. The requested maximum conducted and radiated
power limits will provide exibility to support a wide range of complementary advanced
technology development and experimentation. [REDACTED].3 [REDACTED]. [REDACTED].
Additionally, Google requests authority to conduct narrowband propagation testing in the
3550-3575 MHz segment using a maximum conducted power of 47 dBm and a maximum
radiated power of 77 dBm (assuming the use of a high-gain, narrow beamwidth 30 dBi antenna).
[REDACTED]. [REDACTED]. Google notes that extensive propagation testing has been conducted
in this band under its existing experimental authorization (call sign WH2XNF) in the densely
populated areas of Arlington, Virginia, and Mountain View, California, with no reports of
interference. Google has chosen the 3550-3575 MHz portion as it is removed by at least 75 MHz
from the nearest adjacent-band allocation. Furthermore, the possibility of interference to
authorized users of the band will be mitigated by using narrow beamwidth antennas and
narrowband CW transmissions, along with out-of-band emission levels that will meet or exceed
(i.e., be lower than) the limits in Section 96.41(e) of the Commissions Rules, 47 C.F.R.
96.41(e).
In summary, Google requests authorization to operate up to the following power limits:
2
Call sign WI2XFG (File No. 0095-EX-PL-2016) is associated with 3400-3700 MHz operations in the
Kansas City area. In the present application, Google requests authority to operate up to 3800 MHz in a
limited section of Kansas City, KS.
3
See [REDACTED].
Exhibit A - Page 3

Google Inc.
Planned Testing
Conducted Power Limits
Radiated Power Limits
Broadband Network (3400-3800 40 dBm per 10 MHz

MHz)
power spectral density
49 dBm total conducted

10-MHz aggregate
channels)
57 dBm per 10 MHz radiated

power spectral density
66 dBm total radiated power

(assumes eight 10-MHz
aggregate channels)
Narrowband Propagation
(3550-3575 MHz)
77 dBm
47 dBm
Below, Google explains its plans for protection of the following incumbent users in the
3400-3800 MHz frequency range.
Frequencies
Users
3400-3500 MHz
Military radar systems

Amateur radio
3500-3650 MHz
Shipborne military radar systems
3600-3700 MHz
Grandfathered FSS receive-only earth

stations
3650-3700 MHz
Ground-based military radar systems

Part 90, Subpart Z operators
3700 MHz
FSS receive-only earth stations
Protection of Military Radar Systems Below 3500 MHz

In the 3100-3500 MHz band, the U.S. military operates radar systems on ships and at
several land-based military installations around the country. To protect such uses, Google will
ensure that the signals from its experimental operations remain at or below levels that would
reasonably preclude the possibility of interference. Specically, for all test locations within the
coastal exclusion zones (see Figures 1-3 below) or within 150 km of an in-land operations area,
Google will use the NTIA propagation model that was used to compute the coastal exclusion
zones4 (hereafter referred to as the NTIA model) to predict the aggregate interference from its
deployed transmitters operating at or below 3550 MHz to the closest point of the military
operations area (coastal or land-based) and will limit its signal strength to at or below the
ambient noise level of -174 dBm/Hz at that point, as received by an isotropic antenna. In the
4
The model is described on the NTIA website at

https://www.ntia.doc.gov/report/2015/35-ghz-exclusion-zone-analyses-and-methodology.
Exhibit A - Page 4

Google Inc.
calculation, Google will include both fundamental emissions below 3500 MHz and out-of-band
emissions from devices operating above 3500 MHz.
Amateur Radio Operations in 3400-3500 MHz
The amateur radio service has a secondary allocation in the 3300-3500 MHz band (3.4
GHz band). Based on Googles spectrum monitoring elsewhere in the U.S., amateur operation in
this band appears to be infrequent and generally point-to-point. However, Google will coordinate
with the amateur radio community to ensure that Googles operations do not interfere with any
amateurs who may be utilizing the 3.4 GHz band. For example, Google will inform the American
Radio Relay League prior to beginning operations in each area and provide contact information
so they can report any suspected interference.
Protection of Shipborne Military Radar Systems in 3500-3650 MHz
In the 3500-3650 MHz band, the U.S. military operates shipborne radars in coastal areas.
To protect such uses, Google will ensure that the signals from the experimental operations
remain at or below levels that would reasonably preclude the possibility of interference.
Alternatively, if operating such that the signals could exceed the interference threshold at the
coast, Google will operate a sensor to detect military radar operations and recongure its
devices to avoid those frequencies during the operations.
Specically, for all test locations within the coastal exclusion zones established by the
Commission5 (see Figures 1-3 below), Google will use the NTIA model to predict the aggregate
interference from its deployed transmitters to the closest point on the coast6 and limit the signal
strength to at or below the ambient noise level of -174 dBm/Hz at that point, as received by an
isotropic antenna. In the calculation, Google will include both fundamental emissions in
3500-3650 MHz and out-of-band emissions from devices operating below 3500 MHz and above
3650 MHz. If the signal level is predicted to exceed -174 dBm/Hz at the closest point on the
coast, Google will deploy a sensor to detect military radar operations offshore and congure its
devices to avoid the frequency at which the military is operating, and +/-5 MHz on either side.
This is consistent with the operational concept of the ESC in the Part 96 rules.7 Google will use a
prototype ESC sensor for this purpose, which will be designed to meet the WinnForum
requirements on ESC sensitivity.8
5
See 47 C.F.R. 96.15(a)(1), 96.15(a)(3), 96.15(b); see also Letter from Paige Atkins, Associate
Administrator, Ofce of Spectrum Management, National Telecommunications and Information
Administration, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 12-354, at Enclosure 1 (proposing
exclusion zones to protect shipborne radars).
6
In the event of unusual local geography (e.g., a hill or mountain that blocks the path to the nearest point
on the coast but does not block other paths starting a short distance from that point), Google will analyze
paths to a range of points on the coast and ensure that its signal does not exceed the interference
threshold at any of those points.
7
See 47 C.F.R. 96.67.
8
Specically, [a]n ESC shall be capable of detecting an in-band incumbent radar over a maximum
propagation loss from the radar of 184 dB on the coastline and given a sufciently elevated sensor
location (e.g. 25m) with a clear line-of-sight to the horizon. WINNF-15-S-0112-V1.0.0 CBRS Operational
and Functional Requirements at 27, available online at
http://groups.winnforum.org/p/cm/ld/d=85&tid=338&sid=5781.
Exhibit A - Page 5

Google Inc.
Protection of Grandfathered FSS Receive-Only Earth Station Operations in 3600-3700 MHz
In the 3600-3700 MHz band, FSS receive-only earth stations operate on a grandfathered
basis in accordance with the FCCs rules.9 The earth stations are located at 35 sites that are
largely clustered along the coasts.10 For all test areas subject to Grandfathered FSS Operations
protection requirements (see Figures 1-3 below), Google will meet the Part 96 requirements11
and will conduct its calculations using the NTIA model. In the event that Googles predictions
show that the Part 96 limits may be exceeded for a particular site, Google will coordinate with
the operators of the affected earth station(s).
Protection of Ground-based Military Radar Systems in 3650-3700 MHz
In the 3650-3700 MHz band, the U.S. military conducts research and development (R&D)
activity at three land-based sites whose coordinates are listed in the FCCs rules.12 To protect
such uses, Google will ensure that the signals from its experimental operations remain at or
below levels that would reasonably preclude the possibility of interference. Specically, for all
test locations within 150 km of the R&D sites,13 Google will use the NTIA model to predict the
aggregate interference from its deployed transmitters to the R&D sites and will limit its signal
strength to at or below the ambient noise level of -174 dBm/Hz at that point, as received by an
isotropic antenna. In the calculation, Google will include both fundamental emissions in
3500-3650 MHz and out-of-band emissions from devices operating below 3500 MHz and above
3650 MHz. In general, Google will avoid operating in the 3650-3700 MHz band unless necessary
for the purpose of the experiment, as there are many incumbents in this band segment in
addition to the military radar operations.
Protection of Part 90 Incumbents in the 3650-3700 MHz Band
To protect existing Part 90 operations in the 3650-3700 MHz band, Google will
coordinate its proposed experimental transmissions in this band with all Part 90 licensees in the
Commissions ULS database that are within 25 km of a Google transmitter location. Because
there are many Part 90 systems operating in this band segment, and because Google plans to
coordinate with adjacent-band FSS sites, Google will generally avoid using the 3650-3700 MHz
band except when necessary to meet testing objectives, [REDACTED].
Protection of FSS Receive-Only Earth Station Operations in the 3700-4200 MHz Band
Numerous FSS receive-only earth stations operate in the 3700-4200 MHz band (C-band).
To protect such uses, Google will meet the protection requirements for these systems as
established in Part 96. Once again, Google will conduct its calculations using the NTIA model.
Google will meet the in-band protection requirements in 47 C.F.R. 96.17(a), extended to
3700-4200 MHz, since Google will be operating in-band in this segment. In the event that
9
See 47 C.F.R. 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US107.
The sites are listed on the Commissions website at
https://www.fcc.gov/general/35-ghz-band-protected-xed-satellite-servicefss-earth-stations.
11
See 47 C.F.R. 96.17.
12
S
ee 47 C.F.R. 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US109.
13
Consistent with the proposed power levels for its experimental operations, Google will observe a 150
km exclusion zone instead of the 80 km exclusion required by 47 C.F.R. 9
6.15(b)(2).
10
Exhibit A - Page 6

Google Inc.
Googles predictions show Part 96 limits may be exceeded for a particular site, Google will
coordinate with the operators of the affected earth station(s). As previously noted, Google
intends to avoid operations above 3600 MHz due to the number of incumbents, unless such
operations are necessary to meet the objectives of the experiments.
Figures
The following gures show the locations of Googles planned and potential test areas
relative to the locations of incumbents requiring interference protection. The following key
applies to the gures:
Green areas: Locations where Google plans to operate under the requested experimental
authorization, if approved.
Blue areas: Locations where Google may operate under the requested experimental
authorization, if approved.
Gold-colored areas: Protection zones for incumbent federal ground-based radar
operations in the 3100-3500 MHz band.
Red lines: Coastal exclusion zones for incumbent U.S. military shipborne operations in
the 3500-3650 MHz band.
Red circles: Exclusion zones for incumbent U.S. military R&D sites in the 3650-3700 MHz
band, calculated using a 150 km exclusion distance.
Red dots: Incumbent FSS earth stations in the 3600-3700 MHz band.
Exhibit A - Page 7

Google Inc.
Figure 1: Nationwide view of planned and potential test areas
Exhibit A - Page 8

Google Inc.
Figure 2: Close-up of San Francisco Bay area
Exhibit A - Page 9

Google Inc.
Figure 3: Close-up of Reston, VA area
Exhibit A - Page 10

Google Inc.
Conclusion
The proposed experimental operations will advance radio technologies associated with
the new CBRS service and be conducted without harmful interference to other authorized users.
For the foregoing reasons, Google requests approval of this application.
Exhibit A - Page 11
Google Inc.
EXHIBIT B - LIST OF POTENTIAL TEST LOCATIONS
Google requests authorization to operate in the following geographic areas:
City
Geographic Centerpoint
Radius of
Operations
ARIZONA
Phoenix
33 26 54 N, 112 4 27 W
30 km
Atwater
37 22 14 N, 120 34 29 W
30 km
Los Angeles
33 59 43 N, 118 28 35 W
10 km
Mountain View
37 25 16 N, 122 4 14 W
10 km
Palo Alto
37 26 12 N, 122 9 38 W
10 km
San Bruno
37 37 42 N, 122 25 36 W
10 km
San Francisco
37 45 26 N, 122 26 32 W
7 km
San Jose
37 20 14 N, 121 52 58 W
10 km
40 0 27 N, 105 15 43 W
30 km
27 56 59 N, 82 27 26 W
30 km
33 54 42 N, 84 21 26 W
30 km
41 52 41 N, 87 37 48 W
30 km
41 35 36 N, 93 39 51 W
30 km
39 7 34 N, 94 49 34 W
5 km
41 15 28 N, 95 56 8 W
30 km
36 11 12 N, 115 8 23 W
30 km
40 45 0 N, 73 59 37 W
30 km
CALIFORNIA
COLORADO
Boulder
FLORIDA
Tampa
GEORGIA
Atlanta
ILLINOIS
Chicago
IOWA
Des Moines
KANSAS
Kansas City
NEBRASKA
Omaha
NEVADA
Las Vegas
NEW YORK
New York
NORTH CAROLINA
Exhibit B - Page 1
Google Inc.
Raleigh
35 47 44 N, 78 30 55 W
30 km
35 28 8 N, 97 30 53 W
30 km
45 31 26 N, 122 40 10 W
30 km
30 13 0 N, 97 45 4 W
30 km
40 14 29 N, 111 42 44 W
30 km
Blacksburg
37 13 40 N, 80 25 20 W
30 km
Reston
38 57 31 N, 77 21 33 W
40 km
OKLAHOMA
Oklahoma City
OREGON
Portland
TEXAS
Austin
UTAH
Provo
VIRGINIA
Exhibit B - Page 2

Google Inc.
EXHIBIT C - TECHNICAL INFORMATION
Applicant Name:
Google Inc.
Applicant FRN:
0016069502
Legal Contact Details

Name of Contact
Stephanie Selmer
Contact Details
Associate Corporate Counsel

25 Massachusetts Avenue NW, Ninth Floor
Washington, DC 20001
Technical Contact Details

Name of Contact
Dr. Andrew Clegg
Contact Details
1875 Explorer Street, Tenth Floor

Reston, VA 20190
Phone: (202) 370-5644
Email: aclegg@google.com
Transmitter Equipment and Station Details

Radio Information
Equipment
[REDACTED]
Quantity
[REDACTED]
Area of Operation
Operations vary from 7 km to 40 km from the geographic

centerpoint of each test area. See Exhibit B for the specic
areas of operation.
Frequency
[REDACTED]
High (MHz)
Low (MHz)
3800
3400
Amplier Information
Equipment
[REDACTED]
Quantity
[REDACTED]
Area of Operation

Exhibit C - Page 1

Google Inc.
Antenna Details
Antennas
[REDACTED]
Type
Both directional and omnidirectional antennas will

be used.
Quantity
[REDACTED]
Gain
30 dBi max; -4 dBi min
Beam Width at Half-Power Point
Various (5 to 360 Horizontal; 5 to 180 Vertical)
Orientation in Horizontal Plane
Various (0 to 360)
Orientation in Vertical Plane
10 to -30
Radio
Modulation
Emission Bandwidth Maximum

Designator
Power Out
[REDACTED]
Continuous 10H0N0N
waveform
10 Hz
Maximum
EIRP/ERP
50 W1
EIRP =
47 dBW
(50 kW)1
ERP =
44.9 dBW
(31 kW)1
(with 30 dBi
antenna)
[REDACTED]
Digital
10M0W7D
20M0W7D
40M0W7D
60M0W7D
80M0W7D
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
[REDACTED]
Digital
10M0F9W
20M0F9W
40M0F9W
60M0F9W
80M0F9W
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
For 10 W
conducted:
EIRP =
27 dBW
(500 W);
ERP =
24.9 dBW
(305 W)
For 20 W
conducted:
Highpoweroperationlimitedto[REDACTED] inthe35503575MHzbandsegment.
Exhibit C - Page 2

Google Inc.
[REDACTED]
Digital
10M0G7D
20M0G7D
40M0G7D
60M0G7D
80M0G7D
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
[REDACTED]
Digital
10M0GXW
20M0GXW
40M0GXW
60M0GXW
80M0GXW
10 MHz
20 MHz
40 MHz
60 MHz
80 MHz
10 W
20 W
40 W
60 W
80 W
EIRP =
30 dBW
(1000 W);
ERP =
27.9 dBW
(611 W)
For 40 W
conducted:
EIRP =
33 dBW
(2000 W);
ERP =
30.9 dBW
(1222 W)
For 60 W
conducted:
EIRP =
34.8 dBW
(3000 W);
ERP =
32.6 dBW
(1833 W)
For 80 W
conducted:
EIRP =
36 dBW
(4000 W);
ERP =
33.9 dBW
(2444 W)
(all with 17 dBi

antenna)
[REDACTED]
Digital
2M00P0N
2 MHz
4 W
[REDACTED]
Digital
5M00Q7N
10M0Q7N
20M0Q7N
5 MHz
10 MHz
20 MHz
4 W
EIRP =
22 dBW
(160 W)
ERP =
19.9 dBW
(98 W)
Exhibit C - Page 3

Google Inc.
(with 16 dBi
antenna)
Exhibit C - Page 4

Google FCC Wireless Application

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PUBLIC REDACTED VERSION

Public and Redacted Versions of Request for Condential Treatment and

To Whom It May Concern:

Exhibit A - Narrative Statement:

A key component to sharing in this band is the Spectrum Access System

25 and 90 of the Commissions rules.

Propagation Testing: Google will use both a simple continuous wave

Testing of [REDACTED]: Google will test [REDACTED]. In Atlanta, Austin,

[REDACTED] Testing: Google will [REDACTED]. [REDACTED] .

[REDACTED] Testing: Google will investigate [REDACTED].

In order to perform these tests, Google seeks authorization to operate

removed by at least 75 MHz from the nearest adjacent-band allocation.

Conducted Power Limits

Radiated Power Limits

40 dBm per 10 MHz power

49 dBm total conducted

57 dBm per 10 MHz

66 dBm total radiated

Narrowband Propagation 47 dBm

Military radar systems

Shipborne military radar systems

Grandfathered FSS receive-only earth

Ground-based military radar systems

FSS receive-only earth stations

Protection of Military Radar Systems Below 3500 MHz

The model is described on the NTIA website at

ambient noise level of -174 dBm/Hz at that point, as received by an isotropic

See 47 C.F.R. 96.67.

Request for Condential Treatment - Page 7

Green areas: Locations where Google plans to operate under the

Request for Condential Treatment - Page 9

Figure 2: Close-up of San Francisco Bay area

Request for Condential Treatment - Page 10

Figure 3: Close-up of Reston, VA area

Request for Condential Treatment - Page 11

Exhibit C - Technical Information:

Legal Contact Details

Associate Corporate Counsel

Technical Contact Details

Dr. Andrew Clegg

1875 Explorer Street, Tenth Floor

Request for Condential Treatment - Page 12

Transmitter Equipment and Station Details

Operations vary from 7 km to 40 km from the

Operations vary from 7 km to 40 km from the

Both directional and omnidirectional antennas

30 dBi max; -4 dBi min

Various (5 to 360 Horizontal; 5 to 180 Vertical)

Request for Condential Treatment - Page 13

Emission Bandwidth Maximum Maximum

Identication of the Commission proceeding in which the information was submitted or

Exhibits A and C were submitted to the Commission in support of the Experimental

Explanation of the degree to which the information concerns a service that is

Consistent with 47 C.F.R. 0.459(d)(l), Google requests notication if release of the

Request for Condential Treatment - Page 17

PUBLIC REDACTED VERSION

PUBLIC REDACTED VERSION

[REDACTED] Testing: Google will [REDACTED]. [REDACTED].

[REDACTED] Testing: Google will investigate [REDACTED].

In order to perform these tests, Google seeks authorization to operate [REDACTED]

PUBLIC REDACTED VERSION

PUBLIC REDACTED VERSION

Conducted Power Limits